What is Multi Screen Media P. Ltd. v. Union of India and Another authority for?

An assessment for an earlier year can be reopened based on a finding of fact made from fresh material discovered during the assessment for a subsequent year. This is permissible even if the earlier assessment involved a full and true disclosure.

Which sections of the Income Tax Act does Multi Screen Media P. Ltd. v. Union of India and Another come up under?

It is most often cited in judgments turning on Section 147, Section 148, Section 143(3), Section 10(23C), Section 11, Section 11(4A).

Multi Screen Media P. Ltd. v. Union of India and Another (324 ITR 54)

Q: How many judgments cite Multi Screen Media P. Ltd. v. Union of India and Another?

39 judgments on BharatTax cite Multi Screen Media P. Ltd. v. Union of India and Another (324 ITR 54), spanning 2016 to 2026.

LASCO CHEMIE PRIVATE LIMITED,DELHI vs. INCOME TAX OFFICER, WARD-15(2), NEW DELHI, DELHI

In the result, the appeal filed by the assessee is allowed

ITA 3811/DEL/2025[2012-13]Status: DisposedITAT Delhi08 Apr 2026AY 2012-13

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarlasco Chemie Private Vs. Income Tax Officer, Limited, Ward-15(2), Delhi 10489 Kalptaru, Sadar Thana Road Motia Khan, New Delhi 110055 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabcl 3502 E Appellant .. Respondent

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR

Section 143(3)Section 147Section 148Section 149Section 151Section 250

…made to following judgements: 16. It has been similarly held in the following decisions: - Ganga Saran & Sons (P) Ltd vs. ITO 130 ITR 1 (SC) - Sheo Nath Singh vs. ACIT 82 ITR 148 (SC) - Biria VXL vs. ACIT 217 ITR 1 (Guj) - Multiscreen Media (P) Ltd. vs UOI 324 ITR 54 (Bom.) - ITO vs. Lakhmani Mewal Das 103 ITR 437, 448 (SC) 17. Reason to believe', it is submitted, cannot be equated with reason to suspect [refer Krown Agro Foods (P) Ltd vx ACIT: 375 ITR 460 (Deli. GS P a g e | 10 Lasco Chemie (P) Ltd. (AY 2012-13) Engineering & Construction Corporation vs DDIT (International Taxation): 357 ITR 335 (Del) 18.…

DCIT 3.2.1, MUMBAI vs. THE NEW INDIA ASSURANCE CO LIMITED, MUMBAI

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

ITA 2830/MUM/2024[2018-19]Status: DisposedITAT Mumbai21 Nov 2025AY 2018-19

Bench: SHRI VIKRAM SINGH YADAV , ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Farooq IraniFor Respondent: Shri Satya Pal Kumar&

Section 115JSection 143(3)Section 147Section 148

…Assessing Officer to reopen an assessment of an earlier year on the basis of a finding of fact made on the basis of fresh material in the course of an assessment for a subsequent assessment year. This court in its judgment in Multiscreen Media (No. 2) [2010] 324 ITR 54 (Bom) also adverted to a decision of the Division Bench in Siemens Information System Ltd. v. Asst. CIT [2007] 295 ITR 333 (Bom). The Division Bench held that the judgment in Siemens Information System [2007] 295 ITR 333 (Bom) would not preclude the Assessing Officer to reopen an assessment for an earlier year on the basis of fresh material which…

DCIT 3.2.1, MUMBAI vs. THE NEW INDIA ASSURANCE CO LIMITED, MUMBAI

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

ITA 2823/MUM/2024[2019-20]Status: DisposedITAT Mumbai21 Nov 2025AY 2019-20

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Farooq IraniFor Respondent: Shri Satya Pal Kumar&

Section 115JSection 143(3)Section 147Section 148

…Assessing Officer to reopen an assessment of an earlier year on the basis of a finding of fact made on the basis of fresh material in the course of an assessment for a subsequent assessment year. This court in its judgment in Multiscreen Media (No. 2) [2010] 324 ITR 54 (Bom) also adverted to a decision of the Division Bench in Siemens Information System Ltd. v. Asst. CIT [2007] 295 ITR 333 (Bom). The Division Bench held that the judgment in Siemens Information System [2007] 295 ITR 333 (Bom) would not preclude the Assessing Officer to reopen an assessment for an earlier year on the basis of fresh material which…

THE NEW INDIA ASSURANCE CO LTD,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(2)(2), MUMBAI

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

ITA 2622/MUM/2024[2018-19]Status: DisposedITAT Mumbai21 Nov 2025AY 2018-19

Bench: SHRI VIKRAM SINGH YADAV , ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Farooq IraniFor Respondent: Shri Satya Pal Kumar&

Section 115JSection 143(3)Section 147Section 148

…Assessing Officer to reopen an assessment of an earlier year on the basis of a finding of fact made on the basis of fresh material in the course of an assessment for a subsequent assessment year. This court in its judgment in Multiscreen Media (No. 2) [2010] 324 ITR 54 (Bom) also adverted to a decision of the Division Bench in Siemens Information System Ltd. v. Asst. CIT [2007] 295 ITR 333 (Bom). The Division Bench held that the judgment in Siemens Information System [2007] 295 ITR 333 (Bom) would not preclude the Assessing Officer to reopen an assessment for an earlier year on the basis of fresh material which…

THE NEW INDIA ASSURANCE CO. LTD ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(2)(2), MUMBAI

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

ITA 2616/MUM/2024[2012-13]Status: DisposedITAT Mumbai21 Nov 2025AY 2012-13

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Farooq IraniFor Respondent: Shri Satya Pal Kumar&

Section 115JSection 143(3)Section 147Section 148

…Assessing Officer to reopen an assessment of an earlier year on the basis of a finding of fact made on the basis of fresh material in the course of an assessment for a subsequent assessment year. This court in its judgment in Multiscreen Media (No. 2) [2010] 324 ITR 54 (Bom) also adverted to a decision of the Division Bench in Siemens Information System Ltd. v. Asst. CIT [2007] 295 ITR 333 (Bom). The Division Bench held that the judgment in Siemens Information System [2007] 295 ITR 333 (Bom) would not preclude the Assessing Officer to reopen an assessment for an earlier year on the basis of fresh material which…

BSES YAMUNA POWER LTD,DELHI vs. ACIT, CIRCLE-5(1), NEW DEL;HI

The appeal of the assessee is allowed on legal issues

ITA 4853/DEL/2017[2008-09]Status: DisposedITAT Delhi16 Apr 2025AY 2008-09

Bench: Shri Anubhav Sharma & Shri Manish Agarwalbses Rajdhani Power Ltd., Dy. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd., Asst. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Yamuna Power Dy. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd. & Ors Vs. Acit Bses Yamuna Power Asst. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv., Sh. Deepesh Jain, Adv. & Sh. Shivam Gupta, Ca Department By Mr. Javed Akhtar, Cit-Dr Date Of Hearing 20/02/2025 Date Of Pronouncement 16/04/2025 O R D E R

Section 143(3)Section 147Section 148Section 154Section 250

…sufficiency of the reasons for the belief cannot be investigated by the court." 52. It has been similarly held in the following decisions: Ganga Saran & Sons (P) Ltd vs. ITO 130 ITR 1 (SC); Birla VXL vs. ACIT 217 ITR 1 (Guj); Multiscreen Media (P) Ltd. vs UOI 324 ITR 54 (Bom.) ITO vs. Lakhmani Mewal Das 103 ITR 437, 448 (SC) Arjun Singh vs. ADIT 246 ITR 363 (MP) Seth Brothers vs. JCIT 251 ITR 270 (Guj.) Bombay Pharma Products vs. ITO 237 ITR 614 (MP) Lokendra Singh Rathore vs. WTO 155 ITR 629 (MP) United Electrical Co. (P) Limited vs. CIT 258 ITR 317 (Del.) 53. In view of the aforesaid, it may be noted that the w…

BSES YAMUNA POWER LTD.,NEW DELHI vs. DCIT, CIRCLE- 5(1), NEW DELHI

The appeal of the assessee is allowed on legal issues

ITA 4852/DEL/2017[2007-08]Status: DisposedITAT Delhi16 Apr 2025AY 2007-08

Bench: Shri Anubhav Sharma & Shri Manish Agarwalbses Rajdhani Power Ltd., Dy. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd., Asst. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Yamuna Power Dy. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd. & Ors Vs. Acit Bses Yamuna Power Asst. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv., Sh. Deepesh Jain, Adv. & Sh. Shivam Gupta, Ca Department By Mr. Javed Akhtar, Cit-Dr Date Of Hearing 20/02/2025 Date Of Pronouncement 16/04/2025 O R D E R

Section 143(3)Section 147Section 148Section 154Section 250

…sufficiency of the reasons for the belief cannot be investigated by the court." 52. It has been similarly held in the following decisions: Ganga Saran & Sons (P) Ltd vs. ITO 130 ITR 1 (SC); Birla VXL vs. ACIT 217 ITR 1 (Guj); Multiscreen Media (P) Ltd. vs UOI 324 ITR 54 (Bom.) ITO vs. Lakhmani Mewal Das 103 ITR 437, 448 (SC) Arjun Singh vs. ADIT 246 ITR 363 (MP) Seth Brothers vs. JCIT 251 ITR 270 (Guj.) Bombay Pharma Products vs. ITO 237 ITR 614 (MP) Lokendra Singh Rathore vs. WTO 155 ITR 629 (MP) United Electrical Co. (P) Limited vs. CIT 258 ITR 317 (Del.) 53. In view of the aforesaid, it may be noted that the w…

MANOJ MADANLAL CHHAJED,PUNE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), PUNE

ITA 2017/PUN/2024[2011-12]Status: DisposedITAT Pune19 Feb 2025AY 2011-12

Section 132Section 132(1)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148

…ere was no merit in plea that petitioner was to be\nrelegated to alternative remedy – Held, yes.”\n38\nITA No.1178/PUN/2023\nITA No.2017/PUN/2024\n34.\nWe find the Hon'ble Bombay High Court in the case of Multiscreen Media\n(P.) Ltd. vs. Union of India (2010) 324 ITR 48 (Bom) has observed as under:\n“10) In dealing with the merits of the rival contentions, it must at the outset\nbe noted that during the course of the proceedings under section 143(3),\nthe Assessing Officer was duly apprised of the circumstance that the\npetitioner was acting as an agent for the collection of subscriptions and for\nprocuring adver…

TIJARIA POLYPIPES LIMITED,JAIPUR vs. DCIT CIRLCE 4, JAIPUR

ITA 616/JPR/2024[2013-14]Status: DisposedITAT Jaipur30 Jan 2025AY 2013-14

For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Anoop Singh, Addl.CIT-DR

Section 143(3)Section 147Section 148Section 68

…e\nlooked into by courts and there must be recording of prima facie belief has also\nbeen held in cases of Raymond woollen mills 236 ITR 34 (SC), Phool Chand\nBjaranglal 203 ITR 456 (SC), K R Sadayappan 63 ITR 219 (SC). In case of Multi\nScreen Media (P) Ltd. 324 ITR 54 (Bom) the Bombay High Court after considering\nthe decision in case of CIT vs. Kelvinator of India Ltd. (2010) 320 ITR 561 (SC)\nhas observed as under:\n\"where the AO purports to exercise power under s.147 within a period of four\nyears from the end of the relevant assessment year, the condition precedent to the\nexercise of the power is the exis…

MEHLI MEHTA MUSIC FOUNDATION,MUMBAI vs. ITO, EXEMPTION WARD-2(4), MUMBAI

Appeal is dismissed

ITA 4307/MUM/2023[2017-18]Status: DisposedITAT Mumbai21 Nov 2024AY 2017-18

Bench: Smt Beena Pillai & Shri Prabhash Shankar

For Appellant: Shri P. J. Pardiwala/ Nitesh Joshi &For Respondent: Shri R. R. Makwana (SR. D.R.)

Section 11Section 143(3)Section 2(15)

…her object of general public utility'. Hence, the AO has tangible material to form reason to belief for the reopening of the case. The AO has relied on the decision of the jurisdictional Bombay High Court in the case of Multiscreen Media (P) Ltd Vs UOI [2010] 324 ITR 54 (Bom) wherein it was held that reassessment on the basis of additional material discovered in assessment proceedings of a subsequent year was justified. The AO also discussed that the change of opinion necessarily postulates and requires application of mind by the AO and formation of opinion at the first instance in the original proceedings. It is…

MEHLI MEHTA MUSIC FOUNDATION,MUMBAI vs. ITO, EXEMPTION WARD-2(4), MUMBAI

ITA 4306/MUM/2023[2016-17]Status: DisposedITAT Mumbai21 Nov 2024AY 2016-17

Bench: Smt Beena Pillai & Shri Prabhash Shankar

For Appellant: Shri P. J. Pardiwala/ Nitesh Joshi &For Respondent: Shri R. R. Makwana (SR. D.R.)

Section 11Section 143(3)Section 2(15)

…her object of general public utility'. Hence, the AO has tangible material to form reason to belief for the reopening of the case. The AO has relied on the decision of the jurisdictional Bombay High Court in the case of Multiscreen Media (P) Ltd Vs UOI [2010] 324 ITR 54 (Bom) wherein it was held that reassessment on the basis of additional material discovered in assessment proceedings of a subsequent year was justified. The AO also discussed that the change of opinion necessarily postulates and requires application of mind by the AO and formation of opinion at the first instance in the original proceedings. It is…

MEHLI MEHTA MUSIC FOUNDATION,MUMBAI vs. INCOME TAX OFFICER, EXEMPTION WARD-2(4), MUMBAI

ITA 4261/MUM/2023[2009-10]Status: DisposedITAT Mumbai21 Nov 2024AY 2009-10

Bench: Smt Beena Pillai & Shri Prabhash Shankar

For Appellant: Shri P. J. Pardiwala/ Nitesh Joshi &For Respondent: Shri R. R. Makwana (SR. D.R.)

Section 11Section 143(3)Section 2(15)

…her object of general public utility'. Hence, the AO has tangible material to form reason to belief for the reopening of the case. The AO has relied on the decision of the jurisdictional Bombay High Court in the case of Multiscreen Media (P) Ltd Vs UOI [2010] 324 ITR 54 (Bom) wherein it was held that reassessment on the basis of additional material discovered in assessment proceedings of a subsequent year was justified. The AO also discussed that the change of opinion necessarily postulates and requires application of mind by the AO and formation of opinion at the first instance in the original proceedings. It is…

MEHLI MEHTA MUSIC FOUNDATION,MUMBAI vs. INCOME TAX OFFICER, EXEMPTION WARD-2(4), MUMBAI

ITA 4260/MUM/2023[2014-15]Status: DisposedITAT Mumbai21 Nov 2024AY 2014-15

Bench: Smt Beena Pillai & Shri Prabhash Shankar

For Appellant: Shri P. J. Pardiwala/ Nitesh Joshi &For Respondent: Shri R. R. Makwana (SR. D.R.)

Section 11Section 143(3)Section 2(15)

…her object of general public utility'. Hence, the AO has tangible material to form reason to belief for the reopening of the case. The AO has relied on the decision of the jurisdictional Bombay High Court in the case of Multiscreen Media (P) Ltd Vs UOI [2010] 324 ITR 54 (Bom) wherein it was held that reassessment on the basis of additional material discovered in assessment proceedings of a subsequent year was justified. The AO also discussed that the change of opinion necessarily postulates and requires application of mind by the AO and formation of opinion at the first instance in the original proceedings. It is…